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ARTICLE · 06 JANUARY 2025

CTA Compliance Restored

Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
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Kelley Drye & Warren LLP

Kelley Drye & Warren LLP

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On December 23, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the immediate enforceability of the Corporate Transparency Act (CTA).

United StatesCorporate/Commercial Law
Wendy A. Clarke
Wendy A. Clarke
Jeffrey Hunter
Jeffrey Hunter
Matthew Luzadder
Matthew Luzadder
Aaron Rosenfeld
Aaron Rosenfeld
Matthew Weir
Matthew Weir

On December 23, 2024, the United States Court of Appeals for the Fifth Circuit reinstated the immediate enforceability of the Corporate Transparency Act (CTA). In the case Texas Top Cop Shop, Inc. v. Garland, a three-judge panel from the Fifth Circuit lifted the nationwide preliminary injunction against the CTA that had been issued on December 3, 2024.

Because reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect, the Department of Treasury has extended the reporting deadlines. Importantly, reporting companies that were created or registered prior to January 1, 2024 now have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. These companies would otherwise have been required to report by January 1, 2025.

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